Title
People vs. Pajanustan
Case
G.R. No. L-38162
Decision Date
May 17, 1980
A 1970 robbery-homicide case involving the brutal murder of four family members; Vicente Pajanustan convicted based on circumstantial evidence, flight, and prior criminal record, upheld by the Supreme Court.
A

Case Summary (G.R. No. L-38162)

Facts of the Case

During the incident, the assailants stole various items from the victims, including cash and personal belongings, amounting to a total value of seven hundred twenty pesos. The victims sustained numerous stab wounds: Jesusimo Aco had multiple wounds, including a fatal stab to the abdomen. Simeona had twenty-three stab wounds, while the two grandsons, Rodolfo and Jose, suffered significant injuries leading to their deaths. Vicente Pajanustan, aged 45, was fed and lodged at the victims' house on the night of the crime along with two unidentified companions. Pajanustan later fled the scene and was arrested almost a year later.

Arraignment and Initial Testimony

Upon his arrest on July 31, 1971, Pajanustan was charged with robbery with homicide. He initially pleaded guilty but later claimed that his companions were responsible for the murders and that he did not directly participate. He stated he left the scene out of fear of his companions and did not report the incident due to fears for his safety. Pajanustan also had a prior criminal record indicating violent behavior.

Trial Proceedings and Testimony

The prosecution filed a second amended information and charged Pajanustan alongside his cousin, Domingo Pajanustan. During the trial, Vicente reiterated his assertion that he was not involved in the killings but did attempt to dissuade his companions. The trial court acquitted Domingo but convicted Vicente of robbery with homicide, considering the circumstances to demonstrate treachery and abuse of confidence.

Evidence and Credibility of Witnesses

The court relied heavily on circumstantial evidence presented, particularly the testimony of Julio Nungay, a nearby farmer. Nungay testified seeing Pajanustan and his companions near the crime scene that night and noted Pajanustan had blood on his shirt, which he dismissed as a mere stain. Nungay's observations undermined Pajanustan's alibi and suggested participation in the crime. The court highlighted that Pajanustan's nervousness and confusion when approached by Nungay, along with his flight from the scene, were significant indicators of guilt.

Legal Principles and Court's Findings

Due to the absence of direct witnesses, Vicente Pajanustan's conviction rested upon circumstantial evidence, which is permissible under Philippine law provided that multiple, proven circumstances collectively point to guilt beyond a reasonable doubt. The court found that the accum

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